Plaintiff obtained a jury verdict for damages on a conversion claim. Plaintiff then obtained a further award of prejudgment interest as damages under Civil Code section 3287 from the date of the jury verdict.
The Court of Appeal affirmed the award of prejudgment interest. Prejudgment interest starting from the date of an injury may be awarded as damages under section 3287(a) if the amount of damages is sufficiently certain. Nothing in section 3287(a) prohibits an award of prejudgment interest starting from the date the jury reached a verdict awarding a specific amount of damages. “[T]he test we glean [for awarding prejudgment interest as damages under section 3287] . . . is: did the defendant actually know the amount owed or from reasonably available information could the defendant have computed that amount.” The court found that when the jury reached its verdict and fixed the amount of damages, the amount owed by the defendant was sufficiently certain to permit an award of prejudgment interest under section 3287(a).
